EPIC Urges Coalition of Financial Agencies To Establish Data Protection Rules and Avoid Dangerous Safe Harbors for Finance AI

July 1, 2021

In comments to the Comptroller of the Currency, Federal Reserve, Federal Deposit Insurance Corporation, Consumer Financial Protection Bureau, and the National Credit Union Administration (Financial Agencies), EPIC highlighted concerns with accuracy and bias of AI systems used by financial actors. EPIC urged the agencies to promulgate rules limiting data collection, sharing, and use, as well as require rigorous impact assessments in order to increase transparency and accountability. EPIC argued that “The adoption of AI by financial actors should not be treated as inevitable, and the agencies are uniquely posed to protect consumers through data collection and use limits, reporting and accountability requirements, and bans on certain discriminatory or untested uses of AI.” EPIC has urged both the White House and Congress to prioritize human rights over AI adoption and has recommended the OECD Principles and the Universal Guidelines for Artificial Intelligence as baseline frameworks for regulating AI and mitigating algorithmic harms.

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